Justia Government & Administrative Law Opinion Summaries

Law enforcement officers in Albany County, Wyoming, arrested an individual who had an outstanding warrant and was found in possession of controlled substances. During the arrest, officers located his truck, had a K9 unit alert to it, and towed it to an evidence bay. After obtaining a warrant, they searched the truck and seized substances later determined not to be illegal drugs. The truck was then released by law enforcement to a towing company, where it was placed in storage pending payment of fees. The owner was not notified of this arrangement until several months later. By the time he learned of the truck’s location, storage fees had accumulated to an amount he could not pay, and the truck was eventually sold at auction. The owner asserted he never received notice that the truck could be sold to cover the fees.The District Court of Albany County heard the owner’s pro se motion for return of the truck or, alternatively, for compensation equal to its value. The State responded that it no longer had possession of the vehicle, as it had been released to the towing company and not seized for forfeiture. After a hearing, the district court denied the motion, concluding it lacked authority to order return of property it no longer possessed or to award money damages under Wyoming Rule of Criminal Procedure 41(g).The Supreme Court of Wyoming reviewed the case and held that a court has no jurisdiction under Rule 41(g) to order the return of property or award damages when the government no longer possesses the property. The court reaffirmed that sovereign immunity bars monetary relief under this rule and that any claim for damages must proceed as a separate civil action under the Wyoming Governmental Claims Act. The Supreme Court of Wyoming affirmed the district court’s denial of the motion. View "Bressette v. State" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

A group of long-term care providers and their associated management company filed cost reports for 2015 with the Mississippi Division of Medicaid (DOM), reporting dividends received from three insurance companies as “other income” rather than offsetting them against insurance costs. This reporting practice had been consistently followed and accepted by DOM for over two decades. When DOM audited the 2015 cost reports around 2018, it changed its approach by offsetting these dividends against current insurance costs, thereby affecting reimbursement rates for services provided by the providers.After DOM made these adjustments, the providers sought reconsideration, but DOM upheld its decision. The providers then pursued an administrative appeal, where a hearing officer found DOM’s adjustments supported by substantial evidence and not arbitrary or capricious, recommending affirmation of DOM’s actions. DOM’s executive director adopted this recommendation. The providers appealed to the Hinds County Chancery Court, which affirmed DOM’s decision, concluding that the State Plan required reference to the Provider Reimbursement Manual (PRM) for guidance, and that DOM acted within its authority and did not violate any statutory or constitutional rights. The chancellor also found no evidence of a written internal policy regarding the treatment of such dividends.On appeal, the Supreme Court of Mississippi reviewed whether DOM’s actions were arbitrary and capricious, whether public notice of the change was required, and other issues. The Court held that DOM’s abrupt reversal of its long-standing unwritten internal policy, without reasonable explanation or public notice, was arbitrary and capricious. The Court further found that public notice was required under federal regulations for significant policy changes affecting payment rates. Accordingly, the Supreme Court of Mississippi reversed the decisions of DOM and the chancery court and rendered judgment in favor of the providers. View "Hattiesburg Medical Park Management Corp. v. Mississippi Division of Medicaid" on Justia Law

A patient received treatment for diabetes at VA facilities from 2016 to 2022. In early 2020, he reported worsening symptoms and expressed dissatisfaction with his medical care, believing negligence contributed to his condition. Two years later, he filed a complaint with the Office of the Inspector General, alleging improper diagnosis and treatment at VA facilities. He also submitted a Standard Form-95 (SF-95) to the Office of the General Counsel, naming himself as claimant and his wife as a witness and property owner. The agency denied his claim, and he was informed of his right to sue. The couple then filed a pro se lawsuit under the Federal Tort Claims Act (FTCA), alleging negligent medical care caused kidney disease. Subsequently, the wife filed her own SF-95, asserting power of attorney, but the agency denied this claim as duplicative and because the couple had already sought judicial remedy.The United States District Court for the Eastern District of Texas, following a magistrate judge’s recommendation, dismissed the wife’s claims for failure to exhaust administrative remedies, dismissed both plaintiffs’ claims as time-barred, and denied leave to amend as futile. The plaintiffs objected, but the district court adopted the recommendations and dismissed the case with prejudice. The plaintiffs appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the district court erred in finding the wife failed to exhaust administrative remedies for her property damage claim, because the administrative filing gave sufficient notice for that claim. However, the Fifth Circuit affirmed the district court’s dismissal on the alternative ground that all claims were barred by the FTCA’s statute of limitations, as the plaintiffs’ injuries and property damages were or should have been known more than two years before the administrative claims were filed. The denial of leave to amend was also affirmed. View "Ellsworth v. Dallas Texas Department of Veteran Affairs" on Justia Law

Riverdale Mills Corporation operates a wire mesh manufacturing facility in Northbridge, Massachusetts. In 2019, the Occupational Safety and Health Administration (OSHA) conducted two investigations at Riverdale’s facility, which resulted in citations alleging violations of safety and health standards under the Occupational Safety and Health Act. Riverdale contested these citations, and after a consolidated hearing before an Administrative Law Judge (ALJ) of the Occupational Safety and Health Review Commission (OSHRC) in 2021, the ALJ affirmed three citation items while vacating or withdrawing the others.Subsequently, in December 2023, Riverdale applied to the ALJ for recovery of attorney’s fees and costs under the Equal Access to Justice Act (EAJA). To establish eligibility for this recovery, Riverdale submitted its 2019 balance sheet as evidence, along with a motion to seal the document due to alleged confidential business information. The Secretary of Labor opposed the motion, arguing Riverdale had not demonstrated sufficient grounds for sealing. After considering submissions from both parties, the ALJ denied Riverdale’s motion to seal, applying balancing tests from D.C. Circuit and First Circuit case law and concluding Riverdale had not shown compelling reasons to overcome the presumption of public access. Riverdale attempted to appeal this denial to the OSHRC Commission, but the Commission automatically dismissed the appeal for lack of quorum.Riverdale then sought interlocutory review from the United States Court of Appeals for the First Circuit. The First Circuit assumed interlocutory jurisdiction under the collateral order doctrine and reviewed the ALJ’s denial for abuse of discretion. It held that Riverdale had waived certain arguments by not raising them earlier and determined the ALJ did not abuse her discretion in denying the motion to seal, finding Riverdale failed to meet its burden to justify sealing the balance sheet. The petition for review was denied. View "Riverdale Mills Corp. v. Chavez-DeRemer" on Justia Law

Rosa A. Camacho, a retired Class II member of the Northern Mariana Islands Retirement Fund, claimed that she was entitled to cost-of-living allowances (COLAs) as part of her retirement benefits. When Camacho entered the Retirement Fund in 1980, COLAs were not part of the retirement package. In 1989, the Commonwealth legislature amended the Retirement Fund Act to provide a two percent COLA. Over the years, this provision was repeatedly modified, suspended, and ultimately repealed in 2011. The Commonwealth’s financial difficulties led to a class action and a subsequent settlement agreement in 2013, which entitled participants to 75% of their “Full Benefits,” as defined by statute or guaranteed by the Commonwealth Constitution.The United States District Court for the Northern Mariana Islands held that Camacho was not entitled to COLAs under the settlement agreement, reasoning that COLAs were not constitutionally protected benefits at the time she joined the Retirement Fund and were discretionary by statute as of 2013. Camacho appealed, arguing that the statutory introduction of COLAs during her membership created a protected right under Article III, section 20(a) of the Commonwealth Constitution.The United States Court of Appeals for the Ninth Circuit certified to the Supreme Court of the Commonwealth of the Northern Mariana Islands the question of whether section 8334(e) of the Retirement Fund Act conferred a constitutionally protected accrued benefit in the form of COLAs for Class II members employed when the Act took effect. The Commonwealth Supreme Court answered in the negative, finding that COLAs were legislative policy adjustments and not protected contractual benefits. In accordance with this interpretation, the Ninth Circuit held that Camacho did not acquire a constitutionally protected right to COLAs under section 8334(e). The district court’s decision was affirmed. View "Camacho v. Northern Mariana Islands Settlement Fund" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

A group of individuals who were instrumental in the campaign to incorporate the City of Erda sought to prevent approximately 8,000 acres from being annexed out of Erda and into Grantsville City. The controversy arose after an entity, Six Mile Ranch, initiated and amended an annexation petition to move land from Erda’s boundaries into Grantsville, during and after Erda’s incorporation process. The Grantsville City Recorder determined that the annexation petition met statutory requirements and certified it, which was followed by Grantsville approving the annexation by ordinance and entering a development agreement for the property. The sponsors challenged the annexation, alleging it violated both statutory requirements and constitutional provisions, and sought to invalidate the annexation ordinance and prevent the Lieutenant Governor from certifying it.In the Third District Court, Tooele County, the sponsors filed a petition for extraordinary relief under rule 65B of the Utah Rules of Civil Procedure. The district court dismissed the petition, concluding that the sponsors lacked statutory, traditional, and alternative standing to challenge the annexation, and denied related motions.On direct appeal, the Supreme Court of the State of Utah affirmed the dismissal but on alternative grounds. The court held that the sponsors, lacking statutory standing, had no other remedy for their statutory claims but failed to demonstrate that rule 65B(d)(2)(B) or the judiciary’s constitutional writ authority permitted relief where a public official had performed their statutory duty, albeit allegedly incorrectly. Regarding the constitutional claims, the court found that a plain, speedy, and adequate remedy was available through declaratory judgment actions, as clarified by recent appellate decisions. Therefore, the sponsors could not obtain extraordinary relief under rule 65B for either set of claims, and the dismissal was affirmed. View "Erda Community Association v. Baugh" on Justia Law

Tamica Rainey, a Chicago police officer, was injured in duty-related car accidents in 2013 and 2015. She was awarded duty disability benefits in 2017 based on injuries to her neck and shoulder. As required by statute, Rainey’s disability status was periodically reviewed, and in 2022, after multiple hearings and submissions of medical records, the Retirement Board of the Policemen’s Annuity and Benefit Fund of the City of Chicago discontinued her duty disability benefits, concluding she was no longer disabled from her duty-related injuries. However, when Rainey attempted to return to work, the police department determined she could not perform her duties.Rainey sought administrative review in the Circuit Court of Cook County, which reversed the Board’s decision, relying on precedent that an officer remains disabled if the department cannot provide a position with needed accommodations. The circuit court also awarded Rainey attorney fees and costs under section 5-228(b) of the Illinois Pension Code. The Board appealed, and the Appellate Court of Illinois, First District, affirmed both the restoration of Rainey’s benefits and the award of attorney fees and costs.The Supreme Court of Illinois reviewed the Board’s challenge to the attorney fees and costs award. The court held that section 5-228(b) of the Illinois Pension Code authorizes an award of attorney fees and costs not only to police officers who successfully challenge the initial denial of duty or occupational disease disability benefits, but also to those who successfully challenge the discontinuation of such benefits. The court rejected the Board’s argument that statutory attorney fee awards are limited to initial applications, finding the statute’s plain language and legislative intent favor such awards for both denial and discontinuation challenges. The Supreme Court affirmed the judgments of the appellate and circuit courts and reversed the Board’s decision. View "Rainey v. Retirement Board of the Policemen & Annuity and Benefit Fund of the City of Chicago" on Justia Law

An 18-year-old driver, Elijah Henry, collided with Melanie Gilliland’s vehicle after running a red light, causing her severe injuries. At the time of the accident, Henry was being followed by Officer Matthew Harvey of the City of Pleasanton Police Department. Officer Harvey had entered a parking lot to investigate possible vehicle break-ins and, upon seeing Henry’s car leave the lot, made a U-turn to follow it. Henry, who had smoked marijuana earlier, accelerated away, fearing police interaction but denying any belief that he was being pursued for arrest. Officer Harvey did not activate his lights or siren and testified that he did not initiate a pursuit under the City’s vehicular pursuit policy.Gilliland sued both Henry and the City for negligence. The City asserted immunity under California Vehicle Code section 17004.7, which protects public entities from liability for damages caused by fleeing suspects if the entity has a compliant vehicular pursuit policy and provides regular training. The Alameda County Superior Court initially denied the City’s motion for summary judgment, finding that neither an actual nor perceived pursuit occurred under the City’s policy definition. However, after a bench trial before a different judge, the court found the City immune, interpreting “pursued” in the statute according to its ordinary meaning rather than the policy’s definition, and concluded Henry believed he was being pursued.The California Court of Appeal, First Appellate District, Division One, reviewed the case and held that the definition of “pursuit” in the public entity’s vehicular pursuit policy governs both actual and perceived pursuits under section 17004.7. The court found the trial court erred by applying the ordinary meaning of “pursued” and reversed the judgment, remanding for further proceedings using the correct legal standard. The main holding is that statutory immunity under section 17004.7 depends on the policy’s definition of pursuit, not the word’s general meaning. View "Gilliland v. City of Pleasanton" on Justia Law